Classification for sustainable growth

The Taxonomy Regulation is the European Union’s common classification system for identifying environmentally sustainable economic activities and forms part of the EU’s action plan on Financing Sustainable Growth.

The Taxonomy Regulation covers six environmental objectives:

• Climate change mitigation
• Climate change adaptation
• Sustainable use and protection of water and marine resources
• Transition to a circular economy
• Pollution prevention and control
• Protection and restoration of biodiversity and ecosystems

BE Group is subject to the Taxonomy’s reporting requirements in accordance with Article 8 of Regulation (EU) 2020/852. The company must therefore disclose how and to what extent its activities are covered by the Taxonomy, as well as how well they meet the technical screening criteria required for being assessed as environmentally sustainable.

Disclosures shall be provided based on three financial key performance indicators to clarify the proportion of the company’s products, services, assets or processes that are covered by the Taxonomy. These key performance indicators are turnover, capital expenditure (CapEx), and operating expenditure (OpEx). For an economic activity, or part of an activity, to be aligned with the Taxonomy, it must contribute to one or more of the six environmental objectives by meeting the technical screening criteria, do no significant harm to any of the other objectives, and be carried out in accordance with certain minimum safeguards. The parts of the company’s operations that meet these criteria may be classified as environmentally sustainable for the relevant financial year.

Delegated regulations considered in the analysis:

• Disclosures Delegated Act (EU) 2021/2178
• Climate Delegated Act (EU) 2021/2139
• Environmental Delegated Act (EU) 2023/2486
• Delegated Act (EU) 2022/1214
• Delegated Act (EU) 2023/2485
• Omnibus Delegated Act (EU) 2026/73

BE Group has opted to apply the simplification rule introduced in the EU Taxonomy on 4 July 2025. This rule enables more proportionate and manageable reporting processes in cases where the relevant economic activities represent a limited part of the business, are clearly immaterial in nature, or where collecting detailed data would be disproportionate to the usefulness of the reporting. As a consequence, the company applies the new standardised templates, whereby all key performance indicators are disclosed in Template 1, representing a change compared to the previous reporting year. Key performance indicators with amounts below 10% of the respective total have been excluded from the KPI disclosures in the template and are instead reported under “Activities not assessed and considered non material” in the template.

Assessment of scope

BE Group’s assessment of the scope of its activities in relation to the EU Taxonomy includes a review of all economic activities covered by the six environmental objectives and their connection to the respective KPIs.

BE Group is an independent steel distributor that purchases material from steel mills and sells it to customers with certain added processing services, such as cutting, sawing, blasting and painting. BE Group belongs to the steel and metals industry, specifically steel trading and steel service, and is primarily classified under NACE code G46.72 – Wholesale of metals. BE Group does not influence the production of the material and does not sell finished products. Based on an evaluation of the Taxonomy Regulation, BE Group has not identified any applicable turnover linked to its criteria and requirements. As a steel distributor, its core business cannot be mapped to any of the economic activities described in the Taxonomy and is therefore not covered by the Regulation at this time. The Taxonomy Regulation focuses on sectors with the greatest potential to contribute to the UN Sustainable Development Goals, which means that BE Group’s main operations are currently outside the scope of the Taxonomy, although this may change in the future.

To gather information and report in accordance with the Regulation, BE Group has in previous years established an internal working group consisting of the CFO, Group Accountant, and Finance Managers in Sweden and Finland. Together with external consultants, the working group has mapped the company’s operations and economic activities using the supplementary delegated acts and annexes that describe the Taxonomy activities and their technical screening criteria, including the use of NACE codes (European statistical classification of economic activities). The working group has updated the analysis to ensure full compliance with the revised reporting requirements applicable for the 2025 financial year. The update includes both a review of changes in applicable EU legislation and Taxonomy-related guidance, as well as an assessment of developments and events in the business that may affect the scope and outcome of the Taxonomy reporting. The purpose has been to ensure that the classification, boundaries, and KPI calculations accurately and transparently reflect the company’s current operations.

BE Group is covered by the following economic activities:

• Transport by motorcycles, passenger cars and light commercial vehicles (6.5)
• Installation, maintenance and repair of energy efficiency equipment (7.3)
• Installation, maintenance and repair of instruments and devices for measuring, regulating and controlling the energy performance of buildings (7.5)
• Acquisition and ownership of buildings (7.7)

All of the above-mentioned activities fall under the environmental objective “Climate change mitigation”. However, the working group has, in accordance with the requirements of the EU Taxonomy, conducted a full review of all relevant activities within each of the six environmental objectives to assess their scope as well as their relevance and alignment with the Group’s operations.

As in previous years, Activity 6.5 relating to the use of company cars, and Activity 7.3 relating to installation of LED lighting in operational facilities, have been identified as applicable. During the year, Activity 7.5 was added due to the installation of energy meters for monitoring and controlling energy consumption in operational facilities.

In addition, BE Group is covered by Activity 7.7 (acquisition and ownership of buildings) following a revised interpretation of accounting treatment under the EU Taxonomy Disclosures Delegated Act. Lease costs that are capitalised on the balance sheet in accordance with IFRS 16 are considered investments and are therefore included in the calculation of the CapEx KPI for Activity 7.7.

This revised interpretation of the accounting treatment represents a change compared with previous years, when lease costs were only included in the denominator of the CapEx calculation and not in the numerator. The updated interpretation ensures that the reporting complies with the requirements set out in the Delegated Act and reflects the EU Taxonomy’s definition of investments in a more accurate and consistent manner.

Derivation of figures

Turnover

The denominator for turnover is the Group’s total revenue as reported in the income statement on page 55.

The working group’s analysis concludes that the Group’s turnover cannot be linked to any economic activity within the scope of the Taxonomy. This means that 0% of turnover is covered for the financial year 2025, consistent with previous years.

OpEx

The working group has identified and assessed applicable activities based on the OpEx incurred during the financial year. OpEx includes renovation measures, short-term leases, maintenance and repair, and other direct expenditure relating to the day-to-day operation of assets and necessary to ensure their continued and efficient functioning. Reference is made to Note 3 , page 71, under Other External Costs in the financial statements.

No applicable activities have been identified for OpEx, and consequently 0% coverage is reported, consistent with previous financial years.

CapEx

Capital expenditure (CapEx) related to assets covered by the EU Taxonomy can be attributed to different economic activities. The company has identified and analysed the applicable activities based on the investments carried out during the financial year. In accordance with Annex I to the Delegated Regulation, the CapEx KPI for the financial year ended 31 December 2025 is calculated as the proportion of Taxonomy covered CapEx in relation to the company’s total CapEx.

Total investments (CapEx) for BE Group are the sum of the additions reported in Note 14 – Other Intangible Assets, Note 15 – Property, Plant and Equipment (Aquisitions), Note 15 – Property, Plant and Equipment (Business Combinations – Buildings), and Note 16 – Right-of-Use Assets (Aquisitions of Right-of-Use Assets) under IFRS 16, as presented in the annual report.

As of the reporting date, the company has not established a Taxonomy aligned CapEx plan.

Activity 6.5 – Transport by motorcycles, passenger cars and light commercial vehicles includes leasing of vehicles classified as passenger cars. BE Group leases vehicles included in the Group’s right of use assets and assessed as covered by this Taxonomy activity. Of the Group’s newly leased vehicles in 2025, 91% are electric vehicles. The company considers that the newly leased electric vehicles meet the technical screening criteria for this activity. CapEx relating to the additions of leased vehicles amounts to SEK 11.3 MSEK in 2025 (21% of total CapEx), compared with SEK 4.5 MSEK (4% of total CapEx) in the previous year. A substantial share of the vehicle fleet has been replaced during the year, leading to an increase in CapEx compared with the previous year.

Activity 7.3 – Installation, maintenance and repair of energy efficiency equipment relates to individual renovation measures involving installation, maintenance and repair of equipment. During the 2025 financial year, BE Group continued its investments in LED lighting in its operational facilities. CapEx related to these installations amounts to SEK 465 thousand (0.9% of total CapEx), compared with SEK 1,8 MSEK (1% of total CapEx) in the previous year. The company has assessed that the LED lighting installations meet the relevant technical screening criteria for Activity 7.3.

Activity 7.5 – Installation, maintenance and repair of instruments and devices for measuring, regulating and controlling the energy performance of buildings covers BE Group’s installation during the year of an electricity meter for real time monitoring of electricity consumption. The purpose of the installation was to enable efficient oversight of energy use and support energy reduction initiatives. This activity falls within the scope of the Taxonomy and is therefore included in the reporting. Related CapEx in 2025 amounts to 81 TSEK (0.2% of total CapEx). This activity was not present in the previous year. The company has confirmed that the installation meets the applicable technical screening criteria.

Activity 7.7 – Acquisition and ownership of buildings is included in this year’s reporting, in contrast to the previous year.

Lease costs capitalised under IFRS 16 amounted to 4,3 MSEK during the financial year (corresponding to 8% of total CapEx).

Assessment of materiality and alignment

The combined CapEx attributable to the assessed activities amounts to SEK 16,118 TSEK, representing 30% of total CapEx. In accordance with the simplification rule introduced through the Omnibus amendments, applicable from the 2025 financial year, Activities 7.3, 7.5 and 7.7 are assessed as immaterial. The underlying CapEx related to these activities is below the 10% materiality threshold and therefore falls into the category of non-material economic activities. No further assessment is therefore undertaken for these activities, and they will be reported in the template below as “Non-assessed activities considered non-material”.

Costs related to Activity 6.5 amount to 21% of total CapEx. These costs must therefore be included in the reporting and assessed for Taxonomy alignment.

BE Group has assessed the alignment of activity 6.5, approximately 91% of the associated costs relate to the acquisition of electric vehicles, meaning that this proportion meets the technical screening criteria. However, BE Group has not, during the financial year, carried out an assessment of whether the activity does no significant harm (DNSH), nor verified compliance with the minimum safeguards. Consequently, the activity is not considered Taxonomy aligned.

Avoidance of double counting

As the economic activities are few and are clearly separated from the reporting, there is no risk of double counting, which has been confirmed through the completion of the analysis. Furthermore, BE Group does not have any material Taxonomy related investment plan to report.